This Privacy Policy describes the way Gool Pay inc., a Minnesota (USA) corporation doing business through our mobile phone application and websites; GoolPay.com. Gool Pay obtains, uses, stores, manages, and disposes of certain information that you, as a user of our services, provide to us. You have certain rights, described below, to know what information we collect, how we use it, and how you may obtain and correct it.

GoolPay first collects information about you and about the person to whom you are sending money (your “Beneficiary”) from the data you supply on the GoolPay.com application (the “App”). When you provide information to GoolPay inc, through the App or otherwise, you are warranting to GoolPay inc. that all of the information you provide to us about yourself and about your Beneficiary is accurate and complete. GoolPay inc. is relying on your warranty when GoolPay inc provides the Service to you. The information you provide includes Personally Identifiable Information, which is defined as information that can be used, on its own or with other information, to identify you.

In addition to the information you provide, GoolPay may have, or may obtain from third parties, information about you or your Beneficiary, some of which may be Personally Identifiable Information. More information about these third parties appears below. GoolPay uses this information to provide its services to you, and to help protect you, the GoolPay service, your Beneficiary and the general public from mistakes, fraud, money- laundering and other problems.

Collection of Information

The initial information we collect from you is the information that you provide to us on the GoolPay.com App. This includes information about yourself, such as your full legal name, address, date of birth, telephone number, email address, last four digits of your social security number (if a U.S. Citizen or Permanent resident), as well as other information and/or documentation that will allow us to verify your identify. You must also provide us with information about an approved payment source, such as your debit card, and information about your Beneficiary, which may include sensitive personal information such as your Beneficiary’s name, address, mobile phone number and/or bank account information. GoolPay.com may also collect information from your mobile phone or other device from which you access the GoolPay App, including your IP (Internet Protocol) address, operating system, device identification information, and other information associated with your access to and use of the App. GoolPay Inc. (Goolpay.com) may also collect information about the websites you have visited prior to accessing the GoolPay service. GoolPay inc. May keep and store such information and associate it with your use, in order to help GoolPay.com identify you and facilitate your use of our service in the future.

GoolPay inc may verify and confirm all of the information that you provide to us (or that we otherwise collect from your accessing the GoolPay App through goolpay.com) with third parties, including the financial institution that issued the payment card you propose to use, and the telecommunications company or financial institution through which your money is sent to your Beneficiary. GoolPay.com may also verify such information with identity verification services, electronic databases, social media companies and credit reporting agencies. GoolPay may share your information with the banks, telecommunications providers and other financial services firms who facilitate payment to your Beneficiary. From time to time, GoolPay inc through goolpay.com may require you and/or your Beneficiary to provide us with additional information and/or documentation to confirm your identity and your eligibility to use the GoolPay service.

When you access the GoolPay app, GoolPay.com may collect and store information regarding your use of the App and the service. This includes information about the frequency with which you access the App, the time you spend there, the way you move through the site, your transfer history, and details regarding the amount of money you transfer and your Beneficiaries.

If you contact us for any reason, whether by telephone, email, text or otherwise, GoolPay may record and store communications that you have with us.

Use of Information

GoolPay.com may maintain and use all of the information and documentation that you provide, as well as information that we derive from your use of the service, and the information that we obtain about you from third parties, in order to provide the GoolPay service to you, and to enable GoolPay inc to comply with laws and regulations, including those intended to prevent fraud, money laundering, and other abuses of the financial system. GoolPay.com may use your information to contact you as necessary to confirm or complete a transaction, and to allow our agents, partners and service providers to fulfill their obligations in providing the GoolPay service to you. GoolPay may also use your information to improve our service, to troubleshoot problems, to develop new products and services, and to create advertising, marketing and promotional campaigns. (More information about GoolPay’s use of your data for marketing and promotion is below.) Finally, GoolPay may disclose your information to third parties, including government agencies, when GoolPay reasonably determines that such disclosure is required by law, such as responses to subpoenas and information requests by law enforcement, financial services regulators or national security authorities.

GoolPay will not sell, rent or otherwise disclose your information to third party marketers or others unaffiliated with GoolPay for the purpose of advertising, promoting or selling other services to you. However, where and to the extent allowed by law, GoolPay may work with third parties to analyze the information that we gather from you when you visit us on- line, including our website, our Facebook page, and our Facebook advertisements, whether or not you use the GoolPay service. GoolPay may use the information we gather there, along with the information we obtain from your use of our service, which may include Personally Identifiable Information, to advertise and promote GoolPay services to you and to others. For example, GoolPay provides data to Facebook’s Ad Manager account and SDK programs, which provide us with information about the ways customers and other visitors access, view and use the GoolPay website and application(goolpay.com). We use that information to create advertisements and promotions; such advertisements and promotions may appear in your Facebook feed or on other sites owned or operated by Facebook, such as Instagram. We may customize our marketing and promotional messages to you based on your use of our service, the information that you provide to us or which we otherwise obtain about you, and algorithms designed to help us anticipate your potential needs, based on your information and the information of others who use GoolPay services. GoolPay believes that such programs provide valuable information and benefits to our current and potential users. However, if you live in a jurisdiction where such use of your data for marketing and promotional purposes requires your permission, GoolPay will not use your data for these purposes unless you “opt in” to such uses.

Protection of personal information collected by GoolPay

GoolPay’s leading security experts and practices help ensure that your Personally Identifiable Information is secure. All such information is stored on servers with state-of-the- art data protection technology, and is accessible only to GoolPay.com employees who, for business purposes, need to access it. We use 128-bit encryption and encode your debit card information as soon as it is entered in the GoolPay.com app, a process that overwrites your details so that they are unreadable by unauthorized parties.

No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Although GoolPay.com uses strong methods to protect the data that you provide to us, and we regularly test our information protection practices and technology, GoolPay.com cannot absolutely guarantee its security. We will, however, notify you of any breach or other compromise that affects your data, promptly and in compliance with applicable law.

Use of Cookies and other Tracking Devices

GoolPay.com uses “cookies” and other tracking devices to help us recognize you, remember your preferences and facilitate your future transactions and other interactions with us. We also use such tracking devices to help us understand consumer behavior on our App, in order to help us improve it and make it easier for future use. You may be able to disable your device’s use of cookies, but that may slow or prevent your ability to use the GoolPay.com service.

Your Right to Access and Correct Your Personal Information

You have the right to access your personal information stored by GoolPay.com, subject to applicable laws and in accordance with relevant data protection regulations and GoolPay’s policies intended to prevent fraud and other abuses of financial services. In order to do so, you can contact us at [email protected]. If the information GoolPay has maintained about you is wrong, incomplete or otherwise inaccurate, you have the right to require GoolPay.com to correct it or correct the information yourself directly in the App. Destruction of Information In general, GoolPay maintains information about each transaction for five years. After that period, GoolPay may destroy such information, and it will no longer be available to you or anyone else. However, there may be circumstances in which GoolPay is required to maintain information for longer periods, if required by law or regulation.

Privacy Policy Changes

GoolPay’s privacy policy may change in the future. If that happens, the revised version will be posted on our website, www.GoolPay.com, and will be sent to current users via the email addresses associated with their GoolPay App registrations.